Private Health Insurance Industry Submission on PCEHR Legislation Paper

The Australian Government is establishing electronic health records with the aim of delivering benefits for patients and clinicians across Australia. The personally controlled electronic health record (PCEHR) system is proposed to enable better access to important health information currently held in dispersed records around the country. It will mean that patients will no longer need to unnecessarily repeat their medical history every time they see a doctor or other health professional.

The Department of Health (DoH) sought feedback on the legislation that will underpin the system – PCEHR Legislation Issues Paper. On the basis of this paper and the feedback received, the Government will be drafting legislation for introduction this year. This legislation will also be released for public consultation prior to being presented to Parliament.

 The PCEHR is a significant change in health care management in Australia and Private Healthcare Australia is very interested in the next iteration of the PCEHR Draft Concept of Operations of the PCEHR System,  as Health Industry Funds want to ensure that they are well positioned to provide good services to their members who take up a Personal Health Indicator. The Legislation Issues Paper is therefore timely.

Private Healthcare Australia prepared a brief submission to comment on key aspects of the issues paper that are of concern and interest to the Private Health Insurance Industry

Key Summary of Industry Feedback on the PCEHR Legislation Issues Paper

  • Private Health Insurance Industry was not specifically addressed as a key participant nor was PHI participation addressed within the PCEHR Draft Concept of Operations of the PCEHR system
  • If the Minister’s desire to have the Funds participate in an expansion of Broader Health Care provision is to be facilitated, an inability to utilise the PCEHR to the fullest may well prevent such a desirable outcome
  •  Funds that do not qualify as a Healthcare Organisation and do not receive a HPI-O identifier will be at a disadvantage to those Funds who do receive an HPI-O identifier
  • PCEHR implementation focus has been on primary care rather than acute settings and therefore the implications for the private health sector are not well understood at this stage or top of mind of those driving implementation.
  • Under the Healthcare identifier legislation 2010, health funds are excluded access to the IHI for certain purposes however access by Funds to the IHI would help streamline hospital provider payments of benefits
  • Funds have considerable amounts of information relating to their individual members health history and this information should be included in the PCEHR so that individuals have a complete picture of their health records
  • It is noted that in order to be consistent with the overall existing record management requirements across jurisdictions, a minimum requirement is for PCEHR records to be stored for 15 years. This would/could place strain on IT capabilities and capacities
  • The requirement to store data in Australia places limitations on potential data warehouse options and precludes emerging and potentially more efficient and cost effective technologies such as cloud or virtualisation
  • There is not currently a coordinated approach to complaints handling regarding PCEHR to ensure the issue behind the complaint is correctly addressed so that PHIO is not dealing with complaints about the eHealth System

Private Healthcare Australia submitted its feedback to the Department on the 3rd of August 2011 and looks forward to working with the Department as it continues through the planning and implementation phases of the PCEHR project.